An EU buyer asks for the carbon emissions of your castings. Before attaching a number to the quotation, establish exactly what they need. A CBAM declaration, a product carbon footprint and a sand-additive consumption report answer different questions.
CBAM for foundries starts with the imported product’s customs classification. Once scope is established, the work becomes practical: identify the responsible importer, assemble the right production records and assess improvements against a measured baseline.
This guide reflects the rules and European Commission guidance checked on 11 September 2026.
First establish whether your casting is covered
The Carbon Border Adjustment Mechanism applies to specified goods imported into the EU. Being made of iron or steel is not enough to establish coverage. Check the eight-digit Combined Nomenclature, or CN, code used for the imported article against Annex I of the CBAM Regulation. Listed headings include 7303, covering cast-iron tubes, pipes and hollow profiles, and 7307, covering iron or steel tube and pipe fittings. CBAM Regulation, Annex I
The distinction matters for general castings: heading 7325, “other cast articles of iron or steel”, is absent from the current Annex I list. Do not use the broader phrase “iron and steel castings are covered” to classify an individual product. Nor does a casting automatically create a CBAM obligation when incorporated into a finished machine: the classification and applicable rules for the imported good still matter. Current covered-goods list
The Commission has proposed extending CBAM to additional downstream goods. Its current legislation page lists that extension as a proposal. Treat future coverage separately from today’s obligations. Commission legislation and proposals
For a buyer enquiry, put the product description, CN code and intended EU importer on the first page of the discussion. A buyer can also request emissions information for procurement purposes independently of CBAM; establish that purpose before commissioning the calculation.
Identify the importer and the annual volume
The authorised CBAM declarant is normally the EU importer or an indirect customs representative acting in that role. The declarant submits the annual declaration and surrenders certificates. A foundry outside the EU supplies the production information needed when its actual emissions are used. Commission definitive-regime overview
The mass exemption is 50 tonnes of net mass per importer per calendar year, aggregated across covered iron and steel, aluminium, cement and fertiliser goods. It is not a separate allowance for each supplier or shipment. If that importer exceeds the threshold, obligations cover the relevant imports for the whole year, including quantities imported before the threshold was crossed. Electricity and hydrogen follow separate rules and are outside this mass exemption. Regulation (EU) 2025/2083
For sales planning, ask the buyer to confirm the importer and its threshold position. The tonnage shipped by your foundry alone cannot answer that question.
The 2026 production records matter before the 2027 deadline
CBAM’s definitive phase began on 1 January 2026. The financial obligation concerns covered 2026 imports even though certificate purchasing begins later. Definitive-regime overview
| Milestone | Date |
|---|---|
| Certificate sales begin | 1 February 2027 |
| First annual declaration and certificate surrender, covering 2026 imports | 30 September 2027 |
Commission certificate-platform notice; amended declaration and surrender deadlines.
The useful action in September is to organise this year’s records while purchase, production and stock information can still be reconciled. The later filing date is not a reason to postpone that work. Agree who supplies each dataset and who resolves a missing supplier record before the year closes.
Use the CBAM boundary for the emissions calculation
For covered iron and steel products listed in Annex II, the definitive regime takes direct emissions into account rather than adding the foundry’s purchased-electricity emissions as a separate indirect-emissions component. Relevant precursor emissions also enter the calculation. A precursor is an input material whose own embedded emissions must be carried forward under the prescribed production route. Precursor treatment can include indirect emissions where the precursor’s applicable rules require them. Commission iron and steel guidance, pages 8–9
A whole-company “Scope 1” total is therefore not automatically the correct number per tonne of castings. Define the installation and production processes, identify relevant inputs, and attribute emissions to the goods concerned. The Commission’s non-EU operator guide explains this monitoring-plan sequence. Quick guide, section 3
Coal dust deserves examination within that accounting exercise. Carbon-containing fuels and materials are relevant source streams; the calculation must use the applicable boundary, material quantities and calculation factors, including the treatment of carbon leaving in products or waste where required. Annual coal-dust purchases multiplied by a generic CO₂ factor do not establish a casting’s CBAM emissions. Commission calculation guidance, sections 4.2 and 4.6.1
Actual data and default values are different routes
An importer may use actual verified emissions or the applicable default values. Where actual emissions are used, independent verification must be performed by a verifier accredited by an EU national accreditation body for the relevant scope. A supplier spreadsheet or a material trial report does not replace that verification. Commission verification guidance
Use the current default tables: the Commission published corrected values in 2026. Compare the applicable default with the installation’s supported actual result before deciding which route to use. Do not assume that measuring automatically produces a lower liability. Current default values and correcting act
For a foundry choosing actual data, retain the trail from source records to calculations to verification. That gives the buyer a number it can explain when queried.
A spot carbon price is not your CBAM bill
For 2026 imports, the Commission sets a price for each quarter using EU ETS auction prices. The relevant price follows the quarter of import. As checked on 11 September, the published prices are €75.36 for Q1 and €75.28 for Q2 per CBAM certificate. Q3 and Q4 prices had not yet been published. From 2027, pricing becomes weekly. Official certificate prices
The number of certificates also depends on the embedded emissions attributable to the imported goods and the adjustment reflecting EU ETS free allocation. That adjustment uses the prescribed benchmarks and production-route information. It is not a universal discount that can be applied to every foundry’s annual coal consumption. Commission free-allocation guidance, section 2.2
A qualifying carbon price already paid during production may also support a deduction, subject to the applicable evidence and rules. Commission definitive-regime overview
Ask for an estimate that shows those inputs. If a quotation contains only annual coal consumption and today’s carbon price, essential parts of the calculation are missing. How the importer’s cost affects your selling price is a commercial discussion; an automatic charge-back should not be assumed.
Give a sand-system change its own measurable test
At Refcoat, the practical starting point is the material decision: what is being added to the sand system, what it costs, and what evidence would justify a change.
For a proposed additive trial, agree a baseline and compare:
- Material use: additions and consumption against a consistent production basis.
- Production: sand-test results, casting rejection and rework records for the trial period.
- Money: actual material spend and recorded production costs, including the replacement additive.
Keep the result specific. Lower coal-dust consumption is a material-use result. A reduction in measured CO is a result for that measured gas. Neither, by itself, demonstrates the same percentage reduction in total casting CO₂ emissions or in a CBAM certificate obligation. Carry any proposed emissions effect through the appropriate calculation and verification process.
That discipline protects both the trial decision and the claim made to a buyer. An additive change should earn its place through the foundry’s measured operating results; a compliance claim needs its own supporting evidence.
Start with the decision you can act on
For CBAM, confirm the imported product code and the buyer’s required emissions dataset first. For a proposed change in sand additives, assemble your present sand-system and production information.
Start the Refcoat sand-system diagnostic to examine that operational baseline. The diagnostic addresses the sand system; it does not produce a certified CBAM emissions calculation, verification report or declaration.